People v. Macal
REITERATIONFacts
The Antecedents: The accused-appellant, Manuel Macal, was charged with parricide for allegedly killing his wife, Auria Ytac Macal, on February 12, 2003. The Information alleged that the killing was done willfully, unlawfully, feloniously, and with evident premeditation, inside their bedroom, using an improvised bladed weapon (belt buckle) and a kitchen knife. Procedural History: The Regional Trial Court (RTC) of Tacloban City, Branch 6, convicted Manuel Macal y Bolasco of parricide and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the conviction with modification, increasing the monetary awards. The case reached the Supreme Court on automatic review. The Petition: The accused-appellant sought review of the CA decision, primarily questioning whether the courts below erred in finding him guilty beyond reasonable doubt of parricide.
Issue(s)
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of parricide. Whether the defense of accident under Article 12(4) of the Revised Penal Code is applicable. Whether the absolutory cause under Article 247 of the Revised Penal Code is applicable.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals finding the accused-appellant guilty beyond reasonable doubt of the crime of parricide, with modifications to the monetary awards.
Ratio Decidendi
On the guilt of the accused-appellant for parricide: The Court held that all the essential elements of parricide were duly established. The spousal relationship between the accused-appellant and the victim, Auria, was admitted by the defense and proven by a marriage certificate. The fact of Auria's death was incontestable, supported by witness testimonies and a Certificate of Death. Crucially, the accused-appellant himself admitted in open court to stabbing his wife, stating that he intended to stab a man he saw with her, but his wife shielded him, resulting in her being hit. This admission directly established his culpability for killing his spouse. On the affirmative defense of accident: The Court ruled that the defense of accident under Article 12(4) of the Revised Penal Code must fail. The requisites for accident are: (1) performing a lawful act; (2) with due care; (3) causing injury by mere accident; and (4) without intention of causing it. The accused-appellant's own testimony revealed he became angry upon seeing his wife with another man, got a knife, and intended to kill the man. This clearly indicates he was not performing a lawful act and had the intention to kill, negating the defense of accident. Furthermore, the defense failed to discharge the burden of proving accident by clear and convincing evidence, relying solely on the accused-appellant's self-serving statements. On the applicability of Article 247 of the Revised Penal Code: The Court found Article 247, an absolutory cause, inapplicable. This provision requires the killing of a spouse in the act of committing sexual intercourse with another or immediately thereafter, upon surprise. The accused-appellant admitted that when he saw his wife with another man, they were merely seated beside each other and conversing. This scenario does not constitute the act of sexual intercourse required for Article 247 to apply. Therefore, the defense failed to prove the vital element of the offense.
Main Doctrine
The elements of parricide are duly established when the prosecution proves the killing of a person, that the deceased was killed by the accused, and that the deceased is the legitimate spouse of the accused. The defense of accident requires the performance of a lawful act with due care, causing injury by mere accident and without intention to cause it. The defense of Article 247 RPC requires the killing of a spouse in the act of committing sexual intercourse with another or immediately thereafter, upon surprise.